DJE’s Day to Day Situation Guide for Affiliates

8/12/2019 DJE’s Day to Day Situation Guide for Affiliates

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Daniel J. Edelman Holdings, Inc. Family of Companies’

Day-to-Day Situation Guide

For AffiliatesCompanion Document to the Code of Ethics and Business Conduct

for Affiliates

APRIL 2018



Day to Day Situation Guide for Affiliates

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Table of Contents

Introduction ............................................................................................................................................ 3

Interacting With the Media .................................................................................................................... 3

Accepting Client Engagements ............................................................................................................... 4

Engaging Experts as Spokespeople ......................................................................................................... 4

Using Writers and Experts to Draft Communications ............................................................................ 5

Conducting Client Campaigns ................................................................................................................. 6

Pitching Broadcast Media ....................................................................................................................... 8

Developing Transparent and Credible Broadcast Tools ......................................................................... 8

Using Matte Releases .............................................................................................................................. 9

Word-of-Mouth Marketing ..................................................................................................................... 9

Third-Party Engagement ....................................................................................................................... 10

Online Engagement ............................................................................................................................... 10

Industry and Practice Area Codes of Conduct ...................................................................................... 11




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Introduction

The DJE Code of Ethics and Business Conduct for

Affiliates provides guidance on legal and ethical

standards that apply to business in general. The

Day-to-Day Situation Guide for Affiliates providesadditional assistance on issues that are specific to

the public relations industry. These two

documents should be consulted in tandem when

conducting work on behalf of the Daniel J.

Edelman Holdings, Inc.1 family of companies.

Interacting With the Media

Please observe the following when working with

the media on client engagements.

• Public Disclosure - Obtain permission from

the client before publicly disclosing

information about them or interacting

with the media on their behalf.

• Transparency and Proper Representation

- When engaging journalists, properly

identify yourself and the client(s) you

represent. Be open about your intentions.

• Pay-for-Play - Do not compensate

members of the media, monetarily or in

any other form in return for an

expectation of coverage. The only

exception would be where the coverage is

appropriately accompanied by clear and

conspicuous disclosure that it’s sponsored

coverage (as in the case of advertorials).

• Travel - Follow local and industry custom

and be transparent with all parties about

the source of funds for a journalist’s

1 Daniel J. Edelman Holdings, Inc. includes Daniel J. Edelman, Inc.,

StrategyOne, Inc. d/b/a Edelman Intelligence, Zeno Group, Assembly

Media, Matter, Inc., United Entertainment Group Holdings, LLC

(UEG), The K Group Public Relations Company, d/b/a Krispr

Communications, Edible, Inc., Edelman Miami Latin America Corp.,

travel. Reimbursement for a journalist’s

travel by a client does not impose any

expectation of coverage by the journalist.

• Engaging Freelance Writers - If you hire a

freelance journalist, disclose that fact to

the client. Make it clear that the freelance

journalist is expected to follow the same

guidelines regarding transparency and

proper representation of themselves and

their client when presenting story ideas to

media outlets for potential publication.

Freelance media relations experts and

consultants hired to do client work on

behalf of Edelman are subject to the

The H & W Group, d/b/a Salutem, The R Group Public Relations

Company, d/b/a Revere, First & 42nd, Inc., and all operating

companies under the Edelman family of companies (collectively

referred to as “Edelman” or “DJE” in this document




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requirements established in the Affiliates

Agreement, the Code of Ethics and

Business Conduct for Affiliates, this Day-

to-Day Situation Guide for Affiliates, the

Code of Ethics for Suppliers and Service

Providers, and, where applicable, the

Edelman Anti-Corruption Policy for Third

Party Business Relationships. The affiliate

must ensure that any freelancer or

consultant engaged to do work on behalf

of Edelman are aware of and abide by

these requirements.

• Sponsored Content – With decreasing

advertising revenue in print media, some

periodicals are increasingly turning to

sponsored content. Some periodicals

allow companies to place content by

directly paying for them or indirectly by

buying advertising. Because sponsored

content can blur the line between

editorial and paid content, they must be

used with caution after due consideration

of transparency and cultural norms.

For example, differentiate sponsoredcontent from editorial content by font or

design style, including it as an insert, or

labeling it as paid content (e.g., with the

words “Advertisement”, “Special

Advertising Section” or “Promotion” in the

header). There are also periodicals, such

as in the travel and real estate industries,

where both advertisers and readers are

aware that most or all of the material is

paid content.

Accepting Client Engagements

When pitching a potential client on an

engagement that will involve Edelman, keep in

mind Edelman’s policies regarding acceptance of

new clients. Strive to consider the best interests

of our clients, Edelman, and society when

determining whether to accept a client

engagement. Think about how any action could

be perceived through the eyes of others, such as

the media, existing clients, or other stakeholders.

• Industry Considerations - Edelman does

not accept engagements for the tobacco

(including e-cigarettes), firearms,

pornography, or coal production

industries.

• Conflict Considerations - Address

potential client conflicts and concerns

about exclusivity before accepting new

clients.

• Reputation Considerations - Avoid

engagements where Edelman’s

involvement with the client, the industry it

is in, or the nature of the engagement

itself could damage Edelman’s reputation.

Engaging Experts as Spokespeople

Please observe the following when engagingexperts as spokespeople for client campaigns.

• Identification - When assessing the

appropriateness of a spokesperson or

expert, strive to identify and analyze all

available information about that

individual. Be prepared to provide

Edelman and the client with a full

accounting of this due diligence. At the

client’s request, formal background checksmay be conducted where allowed by law.

• Training - When the spokesperson is being

trained for communication with the media

(or other audiences), it is critical that the

spokesperson, whether a client employee,

independent expert, celebrity, or other




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figure, understand his/her role in the

campaign, the messages he/she is to relay,

and how he/she is being represented.

• Documentation - The understanding

between the spokesperson or expert andEdelman or its affiliate should be in

writing and at a minimum contain the

spokesperson’s obligations, the rights

being obtained by the client, the total fee,

the length of the engagement, and the

degree to which the client expects the

spokesperson to honor exclusivity.

• Conflict of Interests - When engaging

thought leaders and expert consultants,

respect their independence. Payments

should be made for actual services

rendered and never in a way that could be

misinterpreted as a bribe or other illegal

or improper means to induce product use

or promotion. Make all decisions about

honoraria, expense reimbursement, venue

selection, and relationship disclosure in

accordance with customary and accepted

practices, legal requirements, ethical

considerations, and common sense.

Also remember that payments to experts

in some cases may be regulated by law,

particularly in the case of healthcare

providers. In these cases it’s critically

important to put in place processes and

controls in accordance with regulations

and the client’s compliance requirements

before processing any payments for

services to these experts.

Using Writers and Experts to Draft

Communications

When drafting communications for our clients,

transparency of authorship and relationships with

the experts who are the authors can pose complex

and challenging issues. This especially applies to

practice areas where consumers rely heavily on




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the opinions of experts in making decisions, such

as medical education and publishing, other

aspects of health communications, and financial

communications, or where business ethics have

been questioned.

Help ensure that our clients in all industries

understand the shift in the rules of stakeholder

engagement from interactions that are based on

“sponsored associations” to ones that are based

on trusting relationships.

• When developing communications, insist

that authors are expert and involved in

the given subject matter, research

(medical or other) or, in the case of thedrug and biotech industries, in clinical

trials. Do not encourage or solicit mere

signatories on any communications,

including but not limited to op-eds,

opinion pieces, commentaries, original

research manuscripts, white papers, and

blogs, without first obtaining e-mails and

other written endorsement from the

author acknowledging responsibility for

the content, including agreement with theinformation, commentary, opinions, and

conclusions in said communications.

• Follow applicable guidance established by

the media, journals and international

journal editor groups (e.g., International

Committee of Medical Journal Editors),

industry, and the government about

authorship, disclosure of editorial support,

industry funding and other such issues.

There’s no easy solution or one-size-fits-all

approach to address these issues. Transparency

and disclosure are essential. Consult with your

Edelman engagement manager if you have

questions on a particular situation.

Conducting Client Campaigns

Be aware of legal and regulatory restrictions,

safety considerations, as well as ethical, cultural,

and societal issues that may affect how you

conduct our client campaigns. Laws and

regulations are established at the national,

regional, and local levels and may often vary

significantly based on geography.

• Ethical and Societal Expectations – When

planning client campaigns, consider the

ethical and societal implications. Failure

to do so can result in challenges to our

clients’ and our own integrity. As such

there is a dual mandate: To help clientstell their stories, and help them advance in

an environment that calls for more

transparency, collaboration, and

consideration of societal expectations.

Use the Code of Ethics and Business

Conduct for Affiliates and this Day-to-Day

Situation guide as a reference, and strive

to embrace both the letter and the spirit

of doing what is right in serving Edelman

clients.

• Client Industry Regulations – Many clients

operate in a regulated environment, such

as those in the healthcare or financial

services industries. Understand and

comply with industry-specific regulations

that apply to all client services.

• Rules of the Media or Venue –Follow the

rules and regulations that have been

established for any type of media or

communications channel that is used to

conduct a client campaign.

• Target Audiences – Communication to

target groups and their influencers should

be structured in accordance with

applicable laws and regulations.




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o Do not develop or distribute any

communication about alcohol,

gambling services or products, or

adult products to individuals under

the applicable legal age.

o Distribute communications

materials relating to adult products

or material only to individuals who

are over the age of legal consent

and who have specifically consented

to receive adult marketing.

• Permits and licenses – Local or regional

regulations may require companies to

obtain permits or licenses beforeconducting activities such as door-to-door

campaigns and rallies.

• Intellectual Property – We respect and

preserve intellectual rights in the

marketplace.

• Safety – Use common sense and consider

safety concerns when developing

promotional items, events, or campaigns

on behalf of our clients.

• Sweepstakes – While sweepstakes are

often effective marketing devices, they

are also strictly regulated to prevent

unethical and deceptive marketing

practices and to avoid violation of

applicable gambling laws.

• Privacy – Significant restrictions may apply

to the gathering, use and distribution of

personal information used as part of a

campaign. Never sell, distribute, or use

such information in any way other than as

indicated in the campaign and allowed by

applicable law.

• Telemarketing and Mobile

Communications – Various telemarketing

laws restrict companies or organizations

from making unsolicited marketing

telephone calls to consumers.

• Online activities – A number of laws

regulate online activities, including the

operation of Web sites or online services

directed to children, collection of personal

information from children, and the use of

commercial e-mail.

• Advocacy Organizations – If you

recommend or assist a client in creating

an advocacy organization, be transparentregarding the source of funding and the

organizations and interests that you

represent.

• Guerilla Marketing – If a proposed media

campaign includes elements of guerilla

marketing or uses other non-traditional

ways to generate media attention, be sure

that it meets the guidelines set forth

above, including the need to meet ethicaland societal expectations, safety concerns,




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and so forth. Also, be sure to be

transparent about corporate sponsorship

of such events or activities.

• Special Requests From Clients – It is

possible for a client to ask an affiliate todo something that is unrelated to the

services for which they have been

engaged. While client satisfaction is very

important, be careful not to become

involved in any transaction or situation

that could appear questionable to outside

parties. The request may be an attempt to

circumvent the client’s own internal

controls. Or, in a worst case scenario,

being a party to a transaction that you are

not involved in and have no knowledge or

control over could inadvertently give rise

to allegations of money laundering,

corruption, or other wrongdoing. If you

have any question or concern about a

special request from a client, contact your

Edelman engagement manager.

Pitching Broadcast Media

Regulatory initiatives to protect the credibility of

news and ensure proper disclosure have made

pitching VNRs (video news releases), ANRs (audio

news releases), and paid spokespeople to local TV

and radio stations more challenging. To ensure

transparency and credibility, do not position

client-sponsored packages as news if it is truly

more of a marketing or promotional release.

The challenge for communications professionals is

to effectively deliver clients’ messages in this

changing environment.

Public relations production teams have felt a

chilling effect as several TV stations have backed

away completely from participation in client-

sponsored VNRs and SMTs (satellite media tours).

If you work with stations to ensure news and

other television producers know the source of the

sponsorship, and in turn they can reveal that

information to their audiences, it’s more likely the

clients’ material will be used.

Various regulatory agencies or trade associations

related to communications media have issued

guidelines about VNRs and other video and audio

provided by “non-media third parties.” The

guidelines do not state that stations should

summarily avoid airing VNRs or other client-

sponsored broadcast tools, but as the following

guidelines summary makes clear, stations are

advised to exercise considerable caution.

• TV and radio stations “should protect the

editorial integrity of the video and audio

they air,” using material from non-media

third parties only when it is genuinely

newsworthy and the stations are not able

to capture the video or audio themselves,

e.g., proprietary assembly line footage.

• Stations should clearly disclose the source

of information and label all material

provided by corporate or other non-

editorial sources.

In some jurisdictions, stations failing to disclose

who paid for a segment or otherwise identify the

outside source of a video can be fined.

Developing Transparent and Credible

Broadcast Tools

VNRs, ANRs, and SMTs may be used to provide

stations with access to information and expertise

they might not otherwise be able to obtain. We

continue to recommend, and broadcast media




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continue to use, newsworthy and distinctive video

and audio that does not compromise the integrity

of journalism with overt branding and

commercialism.

VNRs, defined as fully produced and edited TV

news stories (including a “reporter” voiceover),

are seldom sought and rarely used in their

entirety, even in the smallest of markets.

Typically, we recommend producing a VNR only

when a story is so complex that it warrants a full

script and reporter voiceover. We more

frequently recommend B-roll packages. Well-

produced B-rolls contain footage that is not

overtly commercial, sound bites, and background

information, and allow producers and reporters to

easily build and edit their own stories.

Similar rules apply to radio, a medium too often

ignored. ANRs and RMTs (radio media tours)

continue to earn solid results, providing

opportunities to deliver important client messages

to broad target audiences. As with TV news,

nothing turns off producers and reporters faster

than overt commercial messaging. One or two

subtle client or product mentions, and only as

they apply to a truly newsworthy story, is the most

you should try to secure. The messages will

achieve maximum impact when delivered by a

credible spokesperson in his or her sound bite(s),

and not in the “reporter” voiceover.

Producers favor in-studio interviews over

satellite feeds so we recommend putting greater

emphasis identifying spokespeople who can travel

to target markets, as opposed to conducting

SMTs. We also recommend using local

spokespeople who can deliver the client’s

messages clearly, effectively, and credibly.

Please keep in mind the following media relations

basics:

• Collaborate with media to develop good

news stories.

• Find creative ways to deliver compelling

messages.

• Develop smart video and audio packages

that include meaningful footage, sound

bites, and important background

information.

• Adhere to the highest level of ethics.

Using Matte Releases

Matte releases are special news releases that are

structured with non-copyrighted editorial material

that a print outlet may choose to use in its original

form. When assisting in distribution of such

materials, clearly communicate the client’s name

or product or service for which the release was

developed.

Word-of-Mouth Marketing

We abide by the Code of Ethics established by the

Word of Mouth Marketing Association

(http://www.womma.org/ethics/womma-code-of-

ethics). The following principles are expressed

and described more fully in the WOMMA Code

and are similar to those that apply to any of our

other client services, including:

• Consumer protection and respect are

paramount

• The Honesty ROI: Honesty of relationship,opinion and identity

• Respect the rules of the venue

• Manage relationships with minors

responsibly

• Promote honest downstream

communications




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• Protect privacy and permission standards

Some jurisdictions have implemented regulations

making it a criminal offense for brands to seed

positive messages online without making the

origin of the message clear. Brand owners will

face fines or even prison sentences if they violate

the consumer-protection regulations.

Third-Party Engagement

Do not implement grass roots campaigns or letter-

writing campaigns to legislators on behalf of

undisclosed interest groups.

Online Engagement

When blogging or engaging in other social media,

keep in mind that the number one goal is to earn

the trust of the audience. With that in mind -

• Proactively disclose your true identity and

affiliation with Edelman and the client you

may be serving.

• Use a disclaimer in your bios on theservices that you use online, so that your

opinions are seen as your own and not

reflective of the opinions of Edelman.

While we recognize that work and

personal lives are separate, they often

blur online.

• Respect the privacy of your colleagues and

the opinions of others. Obtain permission

before sharing a comment, post, picture

or video about a client or colleague

through any type of social media.

• Obtain approval before writing about a

client, a known competitor of that client,

or otherwise responding on Edelman’s or

a client’s behalf.

• Exercise care and discretion in tone and

choice of forum when considering writing

about companies or brands online – they

may be clients, competitors or potential

future clients.

• Identify any copyrighted or borrowed

material with citations and links.

• Evaluate your contribution’s accuracy and

truthfulness before posting.

• Build a reputation of trust among your

clients, media and the public.

• Don’t use your own personal online

relationships or the company’s network to

influence polls, rankings, or web traffic.

• Always be respectful to Edelman, the

client and your audience. This applies to

the type of information posted as well as

the manner and context in which it is

presented.

• Follow the established terms and

conditions of use that have been

established by the venue used for your




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social media activities (Web site, blog,

discussion forum, etc.).

• Obey the law. Don’t post any information

or conduct any online activity that may

violate applicable local, state or federal

laws or regulations.

• Do not directly edit a Wikipedia entry on

behalf of Edelman or a client. Take any

comments, grievances or suggestions to

the “Talk” page of an entry.

Blogging on behalf of Edelman or a client should

be treated the same as any other official

communication and done only with the prior

approval.

Industry and Practice Area Codes of

Conduct

A number of codes of conduct have been

developed by various national and international

public relations, communications, and practice-

specific organizations. Affiliates should take the

time to review the codes that apply to their region

or specialty because outside parties may use them

to evaluate our business practices.




12 | P a g e© 2018 Daniel J. Edelman Holdings, Inc.

Documents

DJE’s Day to Day Situation Guide for Affiliates